Form PF: How Investment Managers Can Prepare in the Face of Uncertainty

Author:

Jordan Dague
Senior Product Manager, Regulatory Reporting at Confluence

With the SEC reviewing its Form PF amendments and the compliance date pushed to October 1, 2025 (for now), investment managers and private fund advisers are left in limbo. Here, we break down three possible outcomes, and help firms determine what they can do now to avoid being caught flat-footed.

A Rule in Limbo: The Current State of Play

After several delays, the SEC has now set October 1, 2025 as the compliance date for its amended Form PF reporting requirements. But this timeline is far from certain.

With a new SEC chair at the helm and a directive to review the rule holistically, both market advocacy groups and industry stakeholders have signaled that further amendments are likely. The Managed Funds Association has formally called for reconsideration of the Form PF update, and SEC leadership has publicly acknowledged the possibility of broader revisions beyond simply extending the deadline.

Understandably, many firms are hesitating to act. Why prepare for a rule that might not go live in its current form? But that logic comes with risk. Regulatory shifts are often announced with little warning. Firms that wait too long could find themselves scrambling to comply.

What’s Happening Now

The SEC’s pause and review approach isn’t just a delay; it’s a signal of the possibility of more change.

The current review is not narrowly focused. Instead, the SEC has indicated it will re-examine the rule broadly, including contentious components like counterparty exposure disclosures and complex fund structure reporting. However, the agency hasn’t provided clarity on which parts it may change, or when.

That leaves firms facing a critical challenge: Do they prepare for the amended form as written, stick with the current version, or wait for the next iteration?

What matters now is to be ready for any of them.

What Could Happen: Three Scenarios—and How to Respond

In this outcome, the SEC proceeds with the current amendments and the deadline holds. This means there is a risk of waiting too long and having to compress implementation into a matter of weeks. Here’s what you can do now to prepare:

• Validate your readiness: Assess whether your current systems and workflows support the amended reporting requirements.
• Run mock filings: Begin testing and validation using the proposed structure and data fields.
• Close internal gaps: Identify key person risk, staffing shortages, or dependencies that could delay compliance.
• Engage your service providers: Ensure your reporting platform supports the new fields and logic, and confirm they align with the rule.

This scenario assumes the SEC will introduce further revisions to the Form PF changes, which would almost certainly push the go-live date further into 2026. With a revised rule and timeline, it presents an opportunity to create a better and faster process by taking these actions:

• Don’t waste the window: Use the extra time to clean up data sources, modernize infrastructure, and eliminate manual workarounds.
• Invest in flexibility: If the form is revised again, your system should be able to accommodate changes without a full rebuild.
• Build workflows that scale: Modular, cloud-based processes can reduce future rework and improve long-term reporting agility.

It’s possible the amended Form PF could be withdrawn or significantly restructured. However, even scrapped regulations can offer a baseline of regulatory reporting capability to meet future requirements. Here are a few steps you can take to leverage the work you’ve already done:

• Focus on foundational readiness: A regulatory reporting infrastructure that is automated, centralized, and cloud-enabled will serve you well no matter the rule.
• Repurpose the work: Any improvements to data quality, validation logic, or process documentation can be leveraged for other filings, such as 13F, AIFMD, and SFDR.
• Keep your partners close: Make sure your technology and service providers are actively monitoring the rule and can advise you on pivot points.

Why Hope Is Not a Strategy

Naturally, there’s a tendency in uncertain regulatory environments to adopt a wait-and-see approach. But inaction can be risky.

A sudden go-live could leave firms out of time and out of compliance. Delays may not be significant, such as a 60-day extension versus a full year. And even with a delay, the reporting burden or the risk of non-compliance isn’t going away.

Form PF readiness is about more than just meeting a deadline. It’s about reducing reporting risk, ensuring data integrity, and maintaining operational resilience.

A trusted partner can help you move with the rule, not chase it, whether that means pivoting quickly or sustaining long-term compliance.

Compliance Uncertainty Is Inevitable, But Being Unprepared Isn’t

Whatever happens next, one thing is certain: preparedness pays off.

Evaluate your current Form PF reporting capabilities, assess your operational plan, and consider whether your existing infrastructure can support the level of agility this regulatory moment demands.

Working with a trusted partner who’s already tracking rule shifts and updating workflows to avoid rework can mean the difference between control and chaos.

With a co-sourcing model, firms can gain flexibility, transparency, and shared responsibility without losing control. You can stay focused on asset growth, while your partner assists to keep your compliance operation future-proof.

Ready or not, change is coming. Make sure you’re ready and then evaluate your current Form PF reporting capabilities and operational plan to lower your reporting risk.

Count on Confluence to Support Form PF Readiness

Whether the SEC moves forward or hits pause again, your firm needs to be prepared. Confluence’s regulatory reporting platform can help you stay ready—without rework, guesswork, or wasted time and expense. Contact us for a walkthrough of how we
can help.

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